Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree domestic-abuse murder and two counts of second-degree murder. Appellant was sentenced to life imprisonment with the possibility of release. The Supreme Court affirmed, holding (1) two courtroom closures did not violate Defendant’s Sixth Amendment right to a public trial because Defendant requested the courtroom closures, and the closures did not seriously affect the fairness, integrity, or public reputation of the judicial proceedings; and (2) any error in the admission of relationship evidence under Minn. Stat. 634.20 of Defendant’s past incidents of domestic abuse against his sister and his former girlfriend was harmless. View "State v. Benton" on Justia Law

Upon executing a warrant to search Defendant’s home for stolen property, law enforcement officers found a locked gun safe in the bedroom. Inside the gun safe were a sawed-off shotgun, a full-length shotgun, and a pistol. No evidence identified Defendant as the owner of the sawed-off shotgun or the pistol. After a jury trial, Defendant was convicted of being a felon in possession of a firearm, in possession of a firearm with no serial number, and in possession of a short-barreled shotgun. Defendant appealed, arguing that there was insufficient evidence that he constructively possessed the firearms in the locked safe. The court of appeals affirmed. The Supreme Court affirmed, holding that under the first prong of State v. Florine, the State established Defendant’s constructive possession of the guns by direct evidence, and therefore, the evidence was sufficient to support the convictions. View "State v. Salyers" on Justia Law

After a jury trial, Appellant was convicted of one count of first-degree premeditated murder and two counts of first-degree felony murder. The Supreme Court consolidated Appellant’s direct appeal and his postconviction appeal and held (1) the mandatory imposition of life without the possibility of release (LWOR) on the first-degree premeditated murder conviction violated the Eighth Amendment’s prohibition on cruel and unusual punishment under Miller v. Alabama; and (2) the postconviction court did not err in denying postconviction relief, the district court did not err in its evidentiary rulings or in imposing consecutive sentences, and the arguments Appellant raised in a pro se supplemental brief were without merit. Remanded for resentencing on the first-degree premeditated murder conviction. View "State v. Ali" on Justia Law

Following a bench trial, Appellant was convicted of three counts of first-degree premeditated murder and sentenced to three consecutive life sentences without the possibility of release. The Supreme Court affirmed Appellant’s convictions on direct appeal, holding (1) the district court did not err in admitting an in-court identification of Appellant; (2) the district court did not abuse its discretion in excluding Appellant’s proposed expert testimony regarding the problems with eyewitness identification; and (3) Appellant was not entitled to a new trial based on alleged prosecutorial misconduct in eliciting three types of inadmissible character evidence. View "State v. Mosley" on Justia Law

Appellant was charged with, and pleaded guilty to, first-degree murder while committing domestic abuse. The district court accepted Appellant’s guilty plea, convicted him, and sentenced him to life imprisonment with the possibility of release. Appellant later filed a motion to withdraw his guilty plea, asserting that enforcing his guilty plea was manifestly unjust because the plea was not accurate, intelligent, or voluntary. The postconviction court denied relief. The Supreme Court affirmed. Appellant then filed a second postconviction petition, alleging that his guilty plea was inaccurate and that the attorney who represented him on his first postconviction petition provided ineffective assistance. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court (1) did not abuse its discretion when it concluded that Appellant’s challenge to his guilty plea was procedurally barred; and (2) did not abuse its discretion when it summarily denied Appellant’s ineffective assistance of postconviction counsel claim because the petition and records conclusively showed that Appellant was not entitled to relief. View "Lussier v. State" on Justia Law

An airport police narcotics investigator removed a package, which was addressed to Defendant, from a conveyor belt at the UPS mail area at the Minneapolis-Saint Paul International Airport, and placed the package on the floor. A trained narcotics-detection dog was brought into the area and alerted to the package. Based on the dog’s alert, an airport police narcotics investigator obtained a warrant authorizing him to open and search the package, which contained cocaine and methamphetamine. Appellant was charged with two counts of a first-degree controlled substance crime. Appellant filed a motion to suppress, arguing that the movement of the package to the floor constituted a seizure, that the dog sniff constituted a search, and that the package was seized and searched without a reasonable, articulable suspicion of criminal activity. The district court denied Petitioner’s motion, concluding that the detention and dog sniff did not constitute a search or seizure. The court of appeals affirmed on other grounds, determining that there was both a search and a seizure but that there was reasonable, articulable suspicion for both. The Supreme Court affirmed on the same basis as the district court, holding that there was neither a search nor a seizure under the facts of this case. View "State v. Eichers" on Justia Law

Minn. Stat. 504B.177 generally places a limitation on late fees for residential housing tenants at eight percent of the overdue rent payment. In this case, Respondent, a tenant living in federally subsidized housing, failed to pay late fees assessed by the Housing and Redevelopment Authority of Duluth (HRA) under his lease. The HRA filed this eviction action for nonpayment of rent. The total amount in arrears was $50. At issue before the district court was whether the monthly $25 late fee provided in the parties’ lease violated section 504B.177. The district court entered judgment for the HRA, concluding that federal law preempts the state limitation on late fees with respect to public housing authorities. The court of appeals reversed. The Supreme Court affirmed, holding (1) the eight percent limitation on late fees in section 504B.177(a) is not preempted by federal law and does not conflict with a federal statute, regulation, or handbook under section 504B.177(b); and (2) therefore, the HRA was subject to the eight percent limitation. View "Housing & Redevelopment Auth. of Duluth v. Lee" on Justia Law

Police officers followed a Chevrolet Monte Carlo that drove away from a house suspected of hosting drug trafficking. The officers subsequently stopped the vehicle after learning that the Monte Carlo’s registration had been revoked and that it was registered to Defendant, whose driver’s license had also been revoked. The driver, who was identified as Defendant, indicated that the car was not insured. The officers decided to tow and impound the vehicle. During an inventory search, the officers found drug and drug paraphernalia in a purse on the passenger seat of the Monte Carlo. Defendant was charged with possession of a controlled substance and possession of drug paraphernalia. Defendant filed a motion to suppress, aruing that the initial stop was lawful but that the search was unconstitutional because the police were not authorized to impound the vehicle, and the inventory search itself was pretextual. The district court denied the motion. The court subsequently found Defendant guilty on both counts. The Supreme Court reversed, holding that the impoundment was unreasonable, and therefore, the resulting inventory search was unconstitutional. View "State v. Rohde" on Justia Law

Appellant was stopped by police officers while driving in a 2003 Chevy Tahoe on suspicion that he did not have a valid driver’s license. Appellant was subsequently issued a traffic citation. The officers proceeded to conduct an inventory search of the Tahoe and found 225 grams of methamphetamine. The officers then searched Appellant and found $611 in cash. Appellant was charged with first-degree possession of a controlled substance. The vehicle and cash were seized, and Appellant was served with notice and intent to forfeit the seized property. Appellant filed a civil complaint demanding a judicial determination of forfeiture, arguing that the Fourth Amendment exclusionary rule applies to civil forfeiture actions and that the evidence supporting forfeiture was illegally obtained and must be suppressed. The district court granted summary judgment for the County. The court of appeals affirmed, concluding that the Fourth Amendment exclusionary rule does not apply to civil forfeiture actions. The Supreme Court reversed, holding (1) the exclusionary rule is applicable to civil forfeiture actions brought under Minn. Stat. 609.531-.5319; and (2) Appellant had standing to challenge the forfeiture of the vehicle and cash. Remanded. View "Garcia-Mendoza v. 2003 Chevy Tahoe" on Justia Law

The State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights. View "State v. Little" on Justia Law